What the AHRC’s Updated DDA Guidelines Mean for Digital Accessibility

In April 2025, the Australian Human Rights Commission released a major update to its Guidelines on Equal Access to Digital Goods and Services. This long-anticipated revision replaces the 2014 Advisory Note and responds to more than a decade of digital transformation.

The release is more than just a technical update; it signals that accessibility is moving to the centre of how governments and businesses are expected to operate in the digital world. The updated guidelines reflect the lived experiences of people with disabilities and the need for digital environments to be designed inclusively from the outset.

A broader understanding of digital accessibility

One of the most immediate and striking changes is the expanded scope of what the Commission defines as “digital goods and services.” No longer confined to websites or web content, the new guidelines apply to a diverse range of technologies. From cloud-based software and mobile apps, to biometric verification systems, extended reality platforms, and the rapidly growing ecosystem of Internet of Things (IoT) devices.

This shift reflects the reality of how people access services in 2025. Everyday interactions, from banking and education to healthcare and employment, are now facilitated by digital tools. The guidelines acknowledge that these tools must be inclusive for all users, including those relying on assistive technologies or those affected by cognitive, sensory, or motor impairments.

A clearer legal context for emerging technology

While the Disability Discrimination Act 1992 remains the legal foundation, the 2025 guidelines take a more proactive stance on what compliance means in a digital-first world. For example, they reaffirm that inaccessible digital services may constitute unlawful discrimination - either direct (excluding someone because of their disability) or indirect (creating barriers through unreasonable conditions, such as requiring biometric input without alternatives).

Significantly, the guidelines highlight two case examples that continue to shape digital accessibility law: Maguire v SOCOG (2000), which confirmed websites as a “service” under the DDA, and Mattiazzo/Innes v CBA, which settled after complaints about the inaccessibility of touch-screen EFTPOS devices. These cases are used to demonstrate how organisations may fall short of legal duties, especially when new technology is introduced without accessibility in mind.

A new baseline for accessibility standards

Another key development is the formal adoption of WCAG 2.2 (released in October 2023) as the minimum accessibility standard expected under the guidelines. This version introduces important updates to address the needs of users with cognitive disabilities and those navigating with keyboards or mobile devices. It strengthens requirements for focus indicators, error prevention, and authentication without memory-based tasks.

The guidelines also endorse the AS EN 301 549 standard for ICT accessibility, bringing Australia into closer alignment with the European Accessibility Act. This standard is particularly relevant for organisations procuring or developing non-web digital products, including software and hardware interfaces.

While WCAG remains the cornerstone for web content, the guidelines now also call out the importance of standards like the Authoring Tool Accessibility Guidelines (ATAG), WAI-ARIA for dynamic content, and EPUB 3.3 for accessible digital publications, pointing to a more integrated, whole-of-system approach to accessibility.

From compliance to risk governance

Perhaps the most consequential change is the Commission’s call for accessibility to be treated as an organisational risk, not just a compliance requirement. The guidelines recommend that organisations embed accessibility considerations into their governance structures, treat accessibility gaps as risks, and monitor them in the same way they would track issues related to cybersecurity or data privacy.

This includes maintaining an accessibility risk register, identifying conformance gaps during procurement processes, and implementing Alternate Access Plans when services cannot yet be made fully accessible. In practice, this means making sure there's a documented fallback for users who encounter inaccessible systems, ensuring no one is denied access simply because a service hasn't yet caught up with the standard.

Rather than seeing accessibility as a checklist to complete at the end of a project, the guidelines now present it as an evolving responsibility. One that must be embedded across the product lifecycle, from ideation through to ongoing maintenance.

Addressing the risks of AI, biometrics, and XR

The 2025 update also introduces more specific language around the risks posed by emerging technologies. AI-powered tools are called out as having the potential to reinforce bias or exclusion if they are not designed inclusively or trained on diverse datasets. The document makes clear that relying on AI for accessibility, such as automated image descriptions or overlays, is not a substitute for well-designed, inclusive systems.

Biometric technologies, such as facial recognition and fingerprint scanners, are similarly flagged for potentially excluding users with disabilities. Organisations deploying these tools are now expected to provide alternative methods of identification and interaction, again underscoring the importance of inclusive design, not just retrofitting.

Extended Reality (XR) platforms and IoT-connected devices are also brought into focus, with the Commission noting how increasingly widespread these tools are becoming and how their default configurations are often inaccessible. In short, accessibility must evolve alongside technology, and these newer tools must be designed with flexibility and equity in mind.

A call to evolve with the times

The 2025 guidelines represent a clear call to action. They mark a turning point in how Australia frames digital accessibility, not just as a legal requirement, but as a human right and a fundamental design principle for an increasingly digital society.

For organisations, this means taking a proactive and strategic approach. It means viewing accessibility as central to product quality, not an afterthought. And it means recognising that good accessibility is good business, offering better user experiences, broader reach, and reduced legal and reputational risk.

The message is clear: if your digital products or services aren’t accessible, they aren’t complete.

Read the full update and access the new guidelines at the Australian Human Rights Commission.

Training and Further Support

Our WCAG Deep Dive Training course is designed to provide a thorough overview of Web Content Accessibility Guidelines (WCAG) 2.2 Level AA and how this can be implemented across websites and digital products.

If you are looking for further support or guidance on how to embed digital accessibility and ensure conformance with these guidelines, you can get in touch.